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Case 18-2868, Document 283, 08/09/2019, 2628241, Page427 of 883 would have substantial impact on visitors to that site. Examples of such articles headlines (examples of actual headlines from the 178 articles) are: e British socialite to face Epstein accuser's defamation lawsuit e Alleged Epstein madam denies calling teen ‘sex slave’ a liar ° Sex-Trafficking Denials Aren't Libel, Brit Says ° U.S. woman who claimed she was forced to have sex with Prince Andrew sues British socialite for denying that she recruited her to be a sex slave e British 'madam' accused of recruiting teenage ‘sex slave' Virginia Roberts for Prince Andrew's friend Jeffrey Epstein denies calling her a liar ° Ghislaine Maxwell denies calling Virginia Roberts a liar ° Bill Clinton Pedophile Sex Scandal: Socialite Denies Calling ENQUIRER Source A Liar, Woman files defamation suit against British publishing magnate ° Jeffrey Epstein sex slave accuser sues Brit socialite for defamation e Lawyers for British socialite accused of pimping ‘sex slave' to Jeffrey Epstein push to dismiss defamation lawsuit. 57. This is a conservative estimate, and more likely than not, articles containing the statements made against Ms. Giuffre have been disseminated to more individuals. X. WHY THE ESTIMATE IS LOW 58. This (66,909,965 individual unique daily traffic) is a conservative estimate, and it is more likely than not, the statements have received wider dissemination due to factors such as: a. Although I spend considerable effort to locate published articles that contained the statements made against Ms. Giuffre, it is reasonable to assume that I have not located all such articles by the time of the submission of this report. So, there are possibly more 26

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Filename DocumentCloud_Epstein_Docs_p01394.png
File Size 284.7 KB
OCR Confidence 94.5%
Has Readable Text Yes
Text Length 1,749 characters
Indexed 2026-02-04 12:28:56.520623